OneLBriefs

Garcia v. San Antonio MTA

SCOTUS- 1985

Facts

Case regarding Congressional wage regulation, through the FLSA, of state government-run mass transit.

Procedural History

SCOTUS overruled Nat'l League of Cities.

Issues

Should Nat'l League of Cities be overruled?

Holding/Rule

The attempt to draw the boundaries of state regulatory immunity in terms of "traditional governmental function" is not only unworkable but also inconsistent with established principles of federalism. Therefore, Nat'l League of Cities is overruled.

There is nothing about applying federal minimum wage requirements to the SAMTA that is destructive of state sovereignty.

Reasoning

There is no good distinction between what activities of the states Congress is allowed/disallowed to regulate that can be made that will be faithful to the role of federalism.

Federal judiciaries are inevitably just going to make these decisions based on which state policies it favors and which it does not since there is no good standard to decide.

Court rejects as unsound and unworkable a rule of state immunity from federal regulation that turns on a judicial appraisal of whether a particular gov't function is "integral" or "traditional."

The States were given a say in Federal government in many ways:

Indirect influence over house of representatives and Senate.

Electoral qualifications give them a role over Presidential elections

The federal political process is effective in preserving the States' interests, and these built-in restraints are enough.

There is nothing about applying federal minimum wage requirements to the SAMTA that is destructive of state sovereignty.

Dissent

(Powell)

This decision substantially alters the federal system embodied in the Constitution.

It essentially reduces the 10th Amendment to meaningless rhetoric.

Notes

Expressly overruled National League of Cities.

When Congress passes generally applicable laws, states can be on the hook to comply with them.

Courts are not going to do judicial review in this area since built-in political process is enough of a safeguard.